Law360, New York ( May 13, 2015, 10:16 AM EDT) -- The Federal Circuit this week rejected the U.S. International Trade Commission's attempt to expand the economic prong of the domestic industry requirement to "qualitative" investments alone, holding that actual, "quantitative" investments must be identified and analyzed to determine whether they are "significant" or "substantial." Lelo Inc. v. ITC, __F.3d__, Slip Op. at 11 (Fed. Cir. May 11, 2015). In Lelo, the commission had found that even though the quantitative investments in the patented components were insignificant relative to overall domestic activities, the components' "crucial" importance to the domestic industry products was sufficient standing alone to satisfy the economic prong. Id. at 6. But in reversing this determination, the Federal Circuit explained that whether investments in a patented component are "crucial" to the domestic industry product is irrelevant, absent "evidence that connects the cost of the components to an increase of investment or employment in the United States." Id....